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It was for this reason that the IILS rejected the rolling average cost method. 362(e)(2)(c) election, the BIL would reduce A's basis in the Newco stock (which, presumably, would not have been sold at the time of the IILS examination; thus, no additional taxes would currently be due). Guidance to avoid disqualification of ISOs substituted or assumed during a corporate transaction (which now includes stock splits and dividends, corporate name changes and other events that the IILS may identify in future guidance); and |
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